Boise Cascade - Executive Summary

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General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 
1.  Accidental Release Prevention and Emergency Response Policies 
We at Boise Cascade are strongly committed to employee, public and environmental safety.  This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility.  It is our policy to implement appropriate controls to prevent possible releases of regulated substances.  In the unlikely event of such a release, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release.  We are also completely coordinated with Koochiching County Sheriff's Department, which provides additional emergency response expertise.  
2.  The Stationary Source and the Regulated Substances Handled 
Boise Cascade owns and operates an integrated pulp  
and paper mill at this location.  We have two regulated substances present at our facility.  These substances include Chlorine and Chlorine Dioxide.  The regulated substances at our facility are involved in several uses.  Chlorine is used for pulp bleaching.  Chlorine Dioxide is used for pulp bleaching and biocide treatment of water in the paper machine and filter plant areas. 
The maximum inventory of Chlorine at our facility is 180,000 lbs. 
The maximum inventory of Chlorine Dioxide at our facility is 29,550 lbs. 
3.  The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario 
To perform the required offsite consequence analysis for our facility, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance for our worst case scenario and Cameo/Aloha modeling software for our alternative release scenarios.  Th 
e following paragraphs provide details of the chosen scenarios. 
The worst case release scenario submitted for the Program 3 toxic substance involves a catastrophic release from Chlorine Storage.  The scenario involves the release of 180000 lb. of Chlorine in a gaseous form over 10 minutes.  Under worst case weather conditions, namely Class F atmospheric stability and 1.5 m/s wind speed, the maximum distance of >25 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. 
One alternative release scenario has been submitted for each Program 3 process.   
The alternative release scenario for Chlorine involves a release in the Chlorine piping system.  The scenario involves the release of 116 lb. of Chlorine.  Toxic liquid is assumed to be released into an indoor blowdown tank where it gasses off.  The release is also assumed to be controlled by active mitigation measures that include caustic neutralization.  Under average weather conditions, the maximum distance to the toxic en 
dpoint of 0.0087 mg/L is 1169 yards. 
The alternative release scenario for Chlorine Dioxide involves a release in the Chlorine Dioxide piping system.  The scenario involves the release of 72 lb. of Chlorine Dioxide. Toxic liquid is assumed to be immediately released indoors to form a pool of height 1 cm, from which evaporation takes place.  The release is also assumed to be controlled by active mitigation measures that include emergency shutdown procedures and pressure drop sensors.  Under average weather conditions, the maximum distance to the toxic endpoint of 0.0028 mg/L is 1760 yards. 
4.  The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. 
The following sections briefly describe the elements of our release prevention program that are in place at our stationary source. 
Process Safety Informat 
Boise Cascade maintains a detailed record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. 
Process Hazard Analysis 
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently.  The methodology used to carry out these analyses is a HAZOP.  The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of five years.  Any findings related to the hazard analysis are addressed in a timely manner. 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, Boise Cascade maintains written operating procedures.  These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and 
startup after a turnaround.  The information is regularly reviewed and is readily accessible to operators involved with the processes.  These procedures are certified annually. 
Boise Cascade has a comprehensive training program in place to ensure that employees that are operating processes are completely competent in the operating procedures associated with these processes.  New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently.  Refresher training is provided at least every year and more frequently as needed. 
Mechanical Integrity 
Boise Cascade carries out highly documented maintenance checks on process equipment to ensure proper functions.  Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps.  Maintenance operations are carried out by qualified p 
ersonnel with previous training in maintenance practices.  Furthermore, these personnel are offered specialized training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
Management of Change 
Written procedures are in place at Boise Cascade to manage changes in process chemicals, technology, equipment and procedures.  Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. 
Pre-startup Reviews 
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Boise Cascade.  These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. 
Compliance Audits 
Boise Cascade conducts aud 
its on a regular basis to determine whether the provisions set out under the RMP rule are being implemented.  These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner.  The previous two audits are kept on file. 
Incident Investigation 
Boise Cascade promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance.  These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring.  All reports are retained for a minimum of 5 years. 
Employee Participation 
Boise Cascade truly believes that process safety management and accident prevention is a team effort.  Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements.  In addition, our employees have acces 
s to all information created as part of the facility's implementation to the RMP rule in particular information resulting from process hazard analyses. 
On occasion, our company hires contractors to conduct specialized maintenance and construction activities.  Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out.  Boise Cascade has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes.  Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 
5.  Five-year Accident History 
Boise Cascade has had an excellent record of preventing accidental releases.  Due to our stringent release prevention policies, over the past five years there have been no accidental releases with offsite consequences and no onsite injuries, deaths or property damage.  
6.  Emergency Response Plan 
Cascade carries a written emergency response plan, which includes dealing with the accidental releases of hazardous materials.  The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. 
To ensure proper functioning, our emergency response equipment is regularly inspected and serviced.  In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 
7.  Planned Changes to Improve Safety 
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program.  One major step is the elimination of chlorine use onsite.  These changes are expected to be implemented by 04/18/01.
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